http://online.wsj.com/articles/ireland-considers-closing-corporate-tax-loophole-1413139198
QuoteIreland Considers Closing Corporate-Tax Loophole
Multinationals Gird for Possible 'Double Irish' Changes; Google, Facebook Would Be Affected
Multinational companies are bracing for their last serving of the "Double Irish."
Ireland is expected on Tuesday to announce changes to its tax code that could eventually close one of the world's most famous corporate-tax loopholes, dubbed the Double Irish, after heavy pressure from governments and the European Union, tax experts say.
Already, companies particularly in the technology and pharmaceutical sectors are setting up battle plans to cope with potential changes.
"A lot of companies are starting to plan now," said Francesca Lagerberg, global leader for tax services at Grant Thornton International. "You can't afford to wait."
The Double Irish uses a twist in Irish laws to funnel royalty payments for intellectual property from one Irish-registered subsidiary to another that resides for tax purposes in a country with no corporate income taxes.
It is often paired with a related tax structure that planners call the "Dutch Sandwich," which uses a Netherlands-based structure to avoid certain taxes. The Double Irish structure allows companies to legally shift billions of euros in profit to tax havens each year.
Companies using the structure or variants include Google Inc., Facebook Inc. and cloud-computing company VMware Inc. according to corporate filings. Google and Facebook have said they pay all the taxes they owe. VMware declined to comment.
Ireland and the Double Irish have become flash points in a broader push to overhaul the corporate tax system. The Organization for Economic Cooperation and Development has said that one goal of its recommended changes to tax laws is to end so-called cash-box arrangements that allow companies to shift profits to tax havens.
The EU has also targeted Ireland for allegedly granting sweetheart tax deals to Apple Inc., AAPL +0.26% something the country and company deny.
The Irish government has bristled at the pressure. "Any changes to Ireland's taxation system is a decision to be taken by government as part of the budgetary process," a spokesman for the Irish finance ministry said, adding that the new budget is due Tuesday.
Tax experts say they expect the country will announce the Double Irish will be phased out, possibly through changes or future changes to the country's tax resident rules. "All the signals we are getting are that it is happening this year," said Feargal O'Rourke, head of tax for PricewaterhouseCoopers in Dublin.
It remains unclear how quickly the changes would take effect. There will likely be a grandfathering clause of between three and seven years to give companies time to plan, tax experts and tech-company officials said. That timeline would overlap with the implementation of recommendations expected from the OECD, which announced its first set in September and will deliver the final batch late next year.
Companies are already considering possible changes to corporate structure, tax experts said. Those could involve closing subsidiaries or shifting where they house their intellectual property. "We've been working with client companies" to figure out "what their options might be," said Anna Scally, a tax partner at KPMG Ireland.
Many of the companies that use the Double Irish are U.S.-based tech companies.
VMware for instance, has an Ireland-registered subsidiary named VMware Bermuda Ltd. that last year pulled in €1.43 billion ($1.8 billion) in licensing fees from the Irish unit that markets and sells VMware software and services, according to a corporate filing. VMware Bermuda paid no corporate income tax last year, the filing says.
A Facebook subsidiary in Ireland reported €1.79 billion in revenue in 2012. But the unit posted a pretax loss of €626,000, after subtracting €1.75 billion in administrative fees, which included royalties for use of the Facebook platform to Facebook Ireland Holdings, which is controlled via the Cayman Islands, according to corporate filings.
Good. :bowler:
[tamas]Communists.[/tamas]
I'd rather have tax havens and those with accounts in them carpet-bombed* to bits, but you can't always get what you want.
* Naval shore bombardment would be ok, too. Though the plan might run into difficulties with Liechtenstein and the like.
That's not very nice.
Multinationals will find another loophole but it's a good step anyways.
"Double Irish"? Sounds like some sort of sex act.
"...and then, after the moustache ride and sixpacking her, I gave her a Double Irish!"
Sounds like knocking her up with twins when she already has 7 kids.
THATS REAL PROTESTANT SIR
Quote from: CountDeMoney on October 14, 2014, 06:21:26 PM
"Double Irish"? Sounds like some sort of sex act.
"...and then, after the moustache ride and sixpacking her, I gave her a Double Irish!"
six packing? :unsure:
If you have to ask, you don't want to know.
It's the punch line to an old joke.
Why are a woman's asshole and vagina so close together?
So you can carry them around like a six pack.
Quote from: derspiess on October 14, 2014, 04:20:56 PM
That's not very nice.
would help persian exports though
Apparently Abbvie has now decided that acquiring Shire Pharma wouldn't be in their best interests...and as a result Shire gets paid 1.6 billion.
Quote from: garbon on October 20, 2014, 06:18:04 PM
Apparently Abbvie has now decided that acquiring Shire Pharma wouldn't be in their best interests...and as a result Shire gets paid 1.6 billion.
lol, Shire. Gotta love a pharmaceutical company whose website has a section on "Share Price" placed in front of the "Our Products" section. How positively Yi.
Quote from: CountDeMoney on October 20, 2014, 09:11:05 PM
Quote from: garbon on October 20, 2014, 06:18:04 PM
Apparently Abbvie has now decided that acquiring Shire Pharma wouldn't be in their best interests...and as a result Shire gets paid 1.6 billion.
lol, Shire. Gotta love a pharmaceutical company whose website has a section on "Share Price" placed in front of the "Our Products" section. How positively Yi.
I just checked Pfizer and Eli Lilly. Both post about their share price in easy to note spot. Roche doesn't show their price (same for AstraZeneca), Novartis has it far down on a scrolling page (same for Abbvie).
Well, that's just a Merry fucking Christmas for them.
Delighted to see Jean-Claude Juncker (PM 1995-2013 and Finance Minister 1989-2009) is there to take on the Irish. At least he has expertise:
http://www.theguardian.com/business/2014/nov/05/-sp-luxembourg-tax-files-tax-avoidance-industrial-scale
EU launches an investigation into state aid in Luxembourg. Juncker who was Finance Minister and Prime Minister for most of the time the comfort letters were being issued was 'not the architect' of Luxembourg's policy. I can only assume he was the interior designer :rolleyes:
QuoteJean-Claude Juncker: I will lead EU campaign against tax avoidance
European commission president, who was finance minister of Luxembourg for 20 years, breaks silence on revelations that Grand Duchy exploited tax loopholes
Share 76
Ian Traynor in Brussels
The Guardian, Wednesday 12 November 2014 14.12 GMT
Jean-Claude Juncker, the head of the European Union executive, has said he would lead a campaign against tax avoidance and evasion, after dominating Luxembourg politics for 20 years during which the Grand Duchy got rich on the most systematic tax avoidance practices known in Europe.
Less than a fortnight into his five-year term as the new president of the European commission, Juncker broke his silence on revelations in the Guardian and other newspapers showing how the Luxembourg tax authorities exploited complex loopholes to enable multinationals to minimise their tax exposure, depriving other EU countries of tens of billions in revenue.
Juncker said he had just ordered the drafting of a new EU directive on automatic exchange of information on national tax rulings between member states, and argued he had supported tax harmonisation in the EU since 1991.
"This commission will fight tax evasion and tax avoidance," he declared. "This is not just words. This is very much the intention."
Asked why anyone should believe him when the evidence suggested his two decades in power in Luxembourg had been a bonanza time for corporate tax avoidance, he replied: "Because I said so."
Questioned as to whether his credibility as a European leader had been shredded by the disclosures of sweet deals for international businesses while he was recommending austerity and public spending cuts, he told an Italian reporter: "I am as suitable [to lead Europe] as you are."
Juncker admitted he had made a mistake by vanishing from public view since the revelation last week of the taxation details contained in a leaked cache of 28,000 pages from PricewaterhouseCoopers documents.
He insisted that everything that occurred in Luxembourg was in line with EU and international norms and regulations. "I am not the architect of the Luxembourg model because this model doesn't exist," he said.
Juncker was finance minister of the Grand Duchy for 20 years till 2009 and simultaneously prime minister for 18 years until losing an election last year. He was the longest-serving prime minister in the EU and chaired the committee of eurozone finance ministers from 2010, throughout the single currency crisis. The committee has been a key body in administering savage austerity in southern Europe and Ireland.
The European commission, the Brussels-based body headed by Juncker since the start of the month, was already investigating alleged tax concessions made by Luxembourg on his watch to Amazon and a subsidiary of Fiat, but last week's revelations go much further, involving scores of companies.
Juncker denied any conflict of interest. "We have a competition commissioner who has a great deal of independence," he said. "I don't understand why the press is producing headlines such as Juncker versus Juncker."
While the Luxembourg regime was legal, Juncker admitted the system was "not always in line with fiscal fairness" and may have breached "ethical and moral standards".
He said he had been completely responsible for what happened under his stewardship of Luxembourg, but at the same time stressed that its tax administration "operates autonomously".
The basis of the industrial-scale tax avoidance system were the tax rulings or "comfort letters" issued by the Luxembourg authorities to PwC acting for its clients. Juncker said such tax rulings were common in 22 of 28 EU member states. The answer to the problem was not to be found in Luxembourg, he said, but through pan-EU moves to enforce "tax harmonisation". This would require the unanimous backing of 28 governments and is viewed as a non-starter.
:bleeding:
The EU really should have learned from last time Luxembourg had President of the European Commission.
Edit: And Der Spiegel with some more details:
http://www.spiegel.de/international/germany/juncker-faces-uncertain-future-amid-tax-loophole-investigations-a-1002062.html
QuoteThe European Commission's competition authorities, it soon became clear, would receive no help from Juncker when they began investigating his country's complicated tax code. It was only after December 2013, when Juncker was voted out of office at home, that Competition Commissioner Joaquín Almunia received information pertaining to a total of 22 questionable tax deals.
Thus far, the Commission is reasonably certain that it can prove Luxembourg granted impermissible state aid in two cases and has opened investigations into both the Luxembourg branch of Amazon and into the automobile multi Fiat Chrysler. Both companies, officials believe, received precise pledges regarding the future tax burdens faced by their Luxembourg-based operations.
In a 30-page letter to the Luxembourg government, Almunia laid out the Commission's suspicions for why Fiat has spent years channeling financial transactions through Luxembourg. The country's tax authorities allegedly accepted a tax savings model developed for Fiat Finance and Trade Ltd. by the financial auditing firm KPMG. Fiat Finance and Trade lends money to other companies within the Fiat group and has a small office on Boulevard Royal not far from the Luxembourg government quarter. The Commission believes that, on Sept. 3, 2012, Fiat Finance and Trade received confirmation of a tax deal that was to run from 2012 to 2016. The result was that Fiat knew precisely how large its tax bill would be each year. According to Commission calculations, Fiat Finance and Trade was assigned annual taxable income of between €2.3 billion and €2.8 billion, regardless of the company's economic performance. The resulting tax bill on such income translates to the laughably small sum of €732,000.
...
Thus far, it seems unlikely that Juncker will lose his position, but that could change. Were it proven that Luxembourg provided illegal state aid to the companies in question, he would stand exposed for having spent years breaking EU law. "Then, it would get tight," says a political colleague, echoing the sentiments of others. "He would hardly be able to endure." EU lawyers are already researching the question as to whether the resignation of a Commission president would force the other 27 commissioners to forfeit their portfolios as well.
Quote
The Guardian
savage austerity
:lol:
QuoteJean-Claude Juncker faces censure vote over Luxembourg tax schemes
Eureopean Union chief's actions as prime minister of Luxembourg attacked over alleged role in creation of tax haven
Ian Traynor in Brussels
The Guardian, Tuesday 18 November 2014 18.39 GMT
Jump to comments (134)
Jean-Claude Juncker is facing a vote in the European parliament to declare him unfit for his post as head of the EU executive because of his alleged role in turning Luxembourg into Europe's biggest tax haven during the two decades he dominated politics in the Grand Duchy.
Far-right and anti-EU MEPs got together on Tuesday to collect enough support for a motion of censure, which must be debated and voted on, possibly as soon asnext week.
The Five Star movement of Italian former stand-up comedian Beppe Grillo is behind the attempt to declare Juncker "intolerable", claiming he has lost his credibility as president of the European commission following the so-called Luxleaks disclosures in the Guardian and other newspapers.
Leaked documents detailed the scale of tax schemes engineered by the Luxembourg authorities for many of the biggest global brands and banks. Juncker was "directly responsible" for the tax scams that saved the multinationals billions and deprived other EU countries of tax revenue, said the motion, supported by Nigel Farage's anti-EU Ukip party. "That commission president Jean-Claude Juncker held the office of prime minister throughout the period of these agreements makes him directly responsible for the tax avoidance policies," said the motion. "A person who is responsible for the creation, the implementation, the governance and the monitoring of these aggressive tax avoidance policies does not have the credibility to serve the European citizens as president of the European commission."
The attempt to skewer Juncker is being led by Grillo's Italian sidekicks. Last week Grillo denounced Juncker as someone "telling us what to do while keeping his money in a tax haven." Marco Zanni, a Five Star MEP, said: "The Luxleaks scandal shows that commission president Juncker in his political life has always acted to enrich his country behind its European partners, in defiance of the union and the community spirit he hopes to represent."
Other groupings are also attempting to raise the pressure on Juncker, who was Luxembourg prime minister for 18 years until last year and finance minister for most of that time.
The far left in the parliament, while refusing to make common cause with the extreme right, is also trying to drum up support for a motion but so far has failed to gather enough signatures. A motion of censure, triggering a full debate and vote, requires the backing of 76 MEPs, or 10% of the total. Tuesday's motion was supported by 44 from the Ukip-led caucus and 32 non-attached MEPs who included Marine Le Pen, the leader of France's National Front. Le Pen and Ukip's Nigel Farage are usually hostile towards one another.
Liberals in the parliament have also been calling for an inquiry into Juncker's record on tax avoidance. The mainstream parties of the centre-right and centre-left, however, as well as many liberals, are solid in their support of Juncker, although there could be social democrat defections in the vote as well as support from some Greens.
The disclosures of the Luxembourg tax arrangements came four days into Juncker's five-year term as commission president. He then vanished for a week. When he reappeared last Wednesday pledging to lead a new EU campaign against tax avoidance, he was summoned to the parliament where a "grand coalition" of the centre-right and centre-left protected him. It was clear on Tuesday that Juncker could count on mainstream support.
Manfred Weber, a German Christian Democrat and floor leader of the European People's party, the parliament's biggest caucus, attacked the motion and defended Juncker. "Europe needs strong and active leadership right now. We will reject this attack on the commission and Europe," he said. "The anti-Europeans are trying again to weaken Europe. A very scurrilous group has banded together."
The motion said: "EU member states have lost billions of euros in potential tax revenues due to aggressive corporate tax avoidance schemes in Luxembourg, established during the period in which the new president of the european commission Juncker held the office of prime minister of the Grand Duchy of Luxembourg. [It] is intolerable that a person who has been responsible for aggressive tax avoidance policies serves as president of the European commission"
God knows how the mainstream parties of Europe are losing support.
QuoteMEP fears 'blood on carpet' in EU tax inquiry
The Greens say the tax inquiry is not a manhunt for Juncker (Photo: europarl.europa.eu)
By NIKOLAJ NIELSEN
BRUSSELS, 2. FEB, 19:17
A proposed MEP inquiry into a tax avoidance scandal that gripped headlines last year has led to a behind-the-scenes power struggle in the European Parliament as key figures are said to be nervous about just who will be brought before the enquiry and what questions will be asked.
The Greens last month obtained enough MEP signatures to set up an inquiry committee into favourable regimes – known as tax rulings – that allow multinationals to pay very little tax, less than one percent in cases.
The inquiry was prompted by the LuxLeaks scandal which saw hundreds of companies benefit from such regimes, set up while the current European Commission president, Jean-Claude Juncker, was prime minister.
The EP's political group leaders are set to endorse the inquiry and then establish the composition of the committee when they meet later this week.
But concerns are mounting that parliament procedures, led by EP president Martin Schulz, to verify the authenticity of the collected signatures and review the legal basis of the committee's mandate may seek to limit the reach of the probe.
The legal service was supposed to have delivered the mandate last week. The delay has raised suspicions among the Greens that moves are being made to water it down.
Schulz's spokesman Armin Machmer told this website on Monday (2 February) that "the expertise of the legal service, which was requested unanimously by all political groups was not available yet. It is due anytime today."
'Blood on the carpet' to be avoided
Belgian Phillippe Lamberts, co-president of the Greens group, told reporters to expect major political repercussions once the inquiry is launched.
If it were to focus on individuals, he raised the concern that there would "be so much blood on the carpet that no one will want to do it because no one can clean it up afterwards".
While this scenario should be avoided, he nevertheless wants a number of people grilled.
Among those on the hit list are Dutch politicians – including finance minister and Eurogroup chief Jeroen Dijsselbloem. The Netherlands has around 12,000 mailbox companies that help channel hundreds of billions of euros each year.
He also wants the EP's liberal leader, Guy Verhofstadt, on the stand for the tax rulings passed under his tenure as Belgian prime minister.
Verhofstadt has taken party credit for having had the idea of setting up a tax enquiry in the first place.
But Lamberts noted Verhofstadt never signed the cross-party list of signatures needed for the committee to see the light of day.
"Mr. Verhofstadt has already supported an inquiry report and it would be inappropriate for him to put his signature twice," said Verhofstadt's spokesperson Bram Delen in an email.
Lamberts also took a shot at Socialist group leader Gianni Pittella.
"Pittella is no better," he said, noting that the Italian MEP had instructed the members in the group not to sign the Green petition.
Lamberts accused the Liberals and the Socialists of having taken their orders from the centre-right EPP group.
"So I decided to speak to Weber [EPP group leader Manfred Weber] rather than the other two. I prefer speaking to God rather than his saints or disciples," he said.
A further twist - breaching jurisprudence?
In a further twist, a confidential legal document distributed by the Greens indicates that Juncker's suggestion, made in the wake of the LuxLeaks scandal, to draw up a law that would oblige member states to share information on these favourable tax regimes, is nothing new.
A directive on the exchange of information to prevent tax evasion has existed since 1977.
It was then revised and updated in 2011.
The directive says when tax rules in one member states result in a loss of tax income in another member state, then member state A has to inform member state B.
The 38-page document, dated 4 June 2012, compiles responses from member states on their application of the directive. Responses were mixed, with some like France providing no information.
"Our legal advisor found over the weekend a jurisprudence [of the European Court of Justice] from 1998, which confirms basically that there is an obligation to exchange information on the most egregious cases of tax rulings," say the Greens.
The revelation means the Greens want to expand the scope of the inquiry to cover maladministration and breach of EU tax law.
Lamberts says the inquiry should be up and running once it goes to vote in the plenary later this month.
This article was updated on Tuesday (3 February) at 15:03 to note that Lamberts wants the inquiry to focus on corporations and not on individuals
Clearly the Greens are the enemies of all humanity.
:lol: :blush:
Though I have immense respect for some other countries' Green parties. It's just ours are full of sociopaths who want to end economic growth and fuck India because at least they're all poor together.
Ok. I don't get it.
Is the European right in favor of high taxes?
Do the European right wing parties stand for liberty, free market, and small gubmint?
Quote from: Siege on February 04, 2015, 02:02:20 PM
Ok. I don't get it.
Is the European right in favor of high taxes?
Do the European right wing parties stand for liberty, free market, and small gubmint?
Of course not. Those are not necessarily right wing ideas. What is right wing or left wing varies. Are Israeli right wing parties for those things?
Quote from: Siege on February 04, 2015, 02:02:20 PM
Do the European right wing parties stand for liberty, free market, and small gubmint?
No, that's what our liberal parties want. Right wing parties here are about hating Islam, immigrants and the EU.
Quote from: Siege on February 04, 2015, 02:02:20 PM
Ok. I don't get it.
Is the European right in favor of high taxes?
Do the European right wing parties stand for liberty, free market, and small gubmint?
No the Euro Right favors orthodoxy, autocracy, and nationalism.
So, like the American right wing.
Quote from: Valmy on February 04, 2015, 02:26:45 PM
Quote from: Siege on February 04, 2015, 02:02:20 PM
Ok. I don't get it.
Is the European right in favor of high taxes?
Do the European right wing parties stand for liberty, free market, and small gubmint?
Of course not. Those are not necessarily right wing ideas. What is right wing or left wing varies. Are Israeli right wing parties for those things?
No. There is no true conservative right wing in the coming israeli elections.
Netanyahu is centrist even though Likud is right, especially after his deal with Hatnua, and he might be even comptemplating a coalition with Labor, which of course he have done before. He is a man of principles, as far as the defense of Israel, but outside of that, his principles are not my conservative principles.
All the other crap like Yisrael Beiteinu, Kulanu, and Yesh Atid, are faux conservative, since they all accept the creation of another arab state in Israeli land.
And the religious parties are anything but conservative. They only care about how much welfare they get for their membership.
Quote from: Razgovory on February 04, 2015, 03:33:30 PM
So, like the American right wing.
If by american right wing you mean the constitutional conservative movement, then you are wrong, since the core values are liberty, free market capitalism, and small goverment.